[AR] Re: Legal for an actual launch
- From: "Monroe L. King Jr." <monroe@xxxxxxxxxxxxxxxxxx>
- To: arocket@xxxxxxxxxxxxx
- Date: Sat, 21 Feb 2015 14:34:04 -0700
Lucky for us there are bomb storage bunkers or magazine from the old
WW2 base that was there with 4 feet thick concrete so we are golden on
storage but we have a lot of sand to move because they where filled in.
Yeah being nice and asking questions helps a lot more than trying to
tell them what you think you know.
As we go here I'll present more interesting questions and be more
specific about what we are doing.
Right now I'm not sure what all codes apply to us but I don't want to
rely totally on what I'm told just in case something get's over looked
and something goes wrong. If something goes wrong I want our ass covered
best as possible.
I've got to cover all the bases for our new shop that's going up first
and I expect we will be heading down there early June.
Monroe
> -------- Original Message --------
> Subject: [AR] Re: Legal for an actual launch
> From: rclague@xxxxxxxxx
> Date: Sat, February 21, 2015 12:33 pm
> To: arocket@xxxxxxxxxxxxx
>
>
> If you follow NFPA Standards for your propellants, plus document and follow
> your own best practices for situations NFPA doesn't cover, storage and
> handling won't give you much trouble.
>
>
>
> -R
>
>
>
> Sent from my Verizon Wireless BlackBerry
>
>
>
> -----Original Message-----
>
> From: Paul Mueller <paul.mueller.iii@xxxxxxxxx>
>
> Sender: arocket-bounce@xxxxxxxxxxxxx
>
> Date: Sat, 21 Feb 2015 12:18:24
>
> To: <arocket@xxxxxxxxxxxxx>
>
> Reply-To: arocket@xxxxxxxxxxxxx
>
> Subject: [AR] Re: Legal for an actual launch
>
>
>
> Monroe,
>
>
>
> NFPA 1127 is the "Code for High Power Rocketry" (bigger than model rockets
>
> but suborbital). I don't think NFPA has a code for orbital rocketry, though
>
> they do have all kinds of codes for flammable liquids, liquid and solid
>
> oxidizers, etc. that could potentially apply to launch site (and possibly
>
> vehicle) design. NFPA by itself doesn't enforce their codes, they have to
>
> be called out in other statutes/regulations as I understand it.
>
>
>
> Paul M
>
>
>
> On Sat, Feb 21, 2015 at 9:27 AM, Monroe L. King Jr. <
>
> monroe@xxxxxxxxxxxxxxxxxx> wrote:
>
>
>
> > I do know that it can be less for hams because Ardusat did it in less
>
> > than 9. So I know they can make exceptions.
>
> >
>
> > It is interesting how fast things change
>
> >
>
> > I'm not even sure it's worth doing a paper on because it does change so
>
> > often. (at least over the last 10 years)
>
> >
>
> > Commercial also invokes the AST branch of the FAA
>
> >
>
> > Also in my endeavors I've never found any branch of the government not
>
> > helpful.
>
> >
>
> > Right now I'm working on my wife's immigration from Canada and it's
>
> > nearly as hard as a launch permit! lol
>
> >
>
> > Monroe
>
> >
>
> >
>
> > > -------- Original Message --------
>
> > > Subject: [AR] Re: Legal for an actual launch
>
> > > From: rclague@xxxxxxxxx
>
> > > Date: Sat, February 21, 2015 12:31 am
>
> > > To: arocket@xxxxxxxxxxxxx
>
> > >
>
> > >
>
> > > Quite sure about the export issue. Was big deal around 2000, so I
>
> > suspect CSLA simply codified in statute what "everyone already knew" but
>
> > the lawyers complained in black and white.
>
> > >
>
> > >
>
> > >
>
> > > Yeah, if you're near water you have to talk with the Coast Guard. I
>
> > offered to call USCG in Alameda for Sphinx flights out of Mojave "if [FAA]
>
> > really wants to go there," but they declined.
>
> > >
>
> > >
>
> > >
>
> > > The 27 months is for hams. Commercial may be less.
>
> > >
>
> > >
>
> > >
>
> > > -R
>
> > >
>
> > >
>
> > >
>
> > > Sent from my Verizon Wireless BlackBerry
>
> > >
>
> > >
>
> > >
>
> > > -----Original Message-----
>
> > >
>
> > > From: "Monroe L. King Jr." <monroe@xxxxxxxxxxxxxxxxxx>
>
> > >
>
> > > Sender: arocket-bounce@xxxxxxxxxxxxx
>
> > >
>
> > > Date: Fri, 20 Feb 2015 20:53:37
>
> > >
>
> > > To: <arocket@xxxxxxxxxxxxx>
>
> > >
>
> > > Reply-To: arocket@xxxxxxxxxxxxx
>
> > >
>
> > > Subject: [AR] Re: Legal for an actual launch
>
> > >
>
> > >
>
> > >
>
> > > Ahhh thank you Randal for the input.
>
> > >
>
> > > Let's see. Your sure about that export issue?
>
> > >
>
> > > Thanks for the AHJ term I can add that to my upcoming write up.
>
> > >
>
> > > I've had a sit down with the locals but yeah it was a while back and I
>
> > > need to do it again. There is no access to the site other than by plane
>
> > > or boat.
>
> > >
>
> > > I should also involve the USCG I forgot about them.
>
> > >
>
> > > Yeah we have time to work with the FCC. Of course we have time to work
>
> > > out issues with all the others too because certainly we will do plenty
>
> > > of sub orbital stuff. But I am planning for the goal so we include it in
>
> > > everything.
>
> > >
>
> > > Yeah the $50 mill was a worst case scenario to scare my investors with
>
> > > if they flinch on that I say next. I'm sure we are under that.
>
> > >
>
> > > International Telecommunication Union ok roger that. Thank you.
>
> > >
>
> > > I missed something or I got something wrong with the UN I looked at a
>
> > > permit at some point along the way here from them. Is that not required
>
> > > anymore or is there something else I missed?
>
> > >
>
> > > Monroe
>
> > >
>
> > > PS I want to get this all down on paper so others can benefit from it
>
> > > as well. I'll also add that I'm using the Vangaurd Engineering Summary
>
> > > as a model for our own summary.
>
> > >
>
> > >
>
> > >
>
> > > > -------- Original Message --------
>
> > > > Subject: [AR] Re: Legal for an actual launch
>
> > > > From: rclague@xxxxxxxxx
>
> > > > Date: Fri, February 20, 2015 8:15 pm
>
> > > > To: arocket@xxxxxxxxxxxxx
>
> > > >
>
> > > >
>
> > > > #1) A useful term of art is the Authority Having Jurisdiction (AHJ).
>
> > That your local Fire Marshal, but calling her the AHJ tells your local EMS
>
> > people that you've done this before and you probably know how.
>
> > > >
>
> > > >
>
> > > >
>
> > > > Sit down with them before you get very far along. They love this stuff
>
> > when it's well planned, hate it when it isn't.
>
> > > >
>
> > > >
>
> > > >
>
> > > > #2) CHP is DOT right down the line. Amateurs don't need to worry about
>
> > transport paperwork if they don't cross a state line. Secure your loads,
>
> > have a manifest and the MSDSs, a point of contact, and the ChemTrec (sp?)
>
> > 800 number.
>
> > > >
>
> > > >
>
> > > >
>
> > > > #3) The FCC stuff will bite you. If you're going to orbit, that's an
>
> > ITU license, and they want 27 months notice.
>
> > > >
>
> > > >
>
> > > >
>
> > > > MPL is Maximum Probable Loss, which at 1E-07 isn't very probable.
>
> > That's how much liability insurance FAA makes you buy. If your MPL is
>
> > $50,000,000, that's a signal that your launch site has too much expensive
>
> > stuff near it. Might want to find another one.
>
> > > >
>
> > > >
>
> > > >
>
> > > > The environmental is an Environment Assessment (EA). EAs cost about a
>
> > million dollars, and the rocket EAs all say No Impact. FAA will tell you
>
> > you have to write the EA. No, they do. It's the license/permit that's the
>
> > Major Federal Action, not the launch. If you have a million dollars,
>
> > burning a hole in your pocket, you can hire someone who will finish it
>
> > sooner than FAA would. RS&H does this kind of work.
>
> > > >
>
> > > >
>
> > > >
>
> > > > A launch is not an export, no tax is levied, and no broker is
>
> > required. That's in statute.
>
> > > >
>
> > > >
>
> > > >
>
> > > > The UN does not issue satellite permits. The ITU does. The
>
> > notification requirements in the Outer Space Treaty are passed through to
>
> > the permittee/licensee by FAA. Orbital parameters, and not even all of them.
>
> > > >
>
> > > >
>
> > > >
>
> > > > -R
>
> > > >
>
> > > >
>
> > > >
>
> > > > Sent from my Verizon Wireless BlackBerry
>
> > > >
>
> > > >
>
> > > >
>
> > > > -----Original Message-----
>
> > > >
>
> > > > From: "Monroe L. King Jr." <monroe@xxxxxxxxxxxxxxxxxx>
>
> > > >
>
> > > > Sender: arocket-bounce@xxxxxxxxxxxxx
>
> > > >
>
> > > > Date: Fri, 20 Feb 2015 18:29:14
>
> > > >
>
> > > > To: Arocket<arocket@xxxxxxxxxxxxx>
>
> > > >
>
> > > > Reply-To: arocket@xxxxxxxxxxxxx
>
> > > >
>
> > > > Subject: [AR] Legal for an actual launch
>
> > > >
>
> > > >
>
> > > >
>
> > > > Ok after a few years work I think I've pretty much covered all the
>
> > > > bases on the legalities of an orbital launch. I want to throw this out
>
> > > > there and see if anyone thinks I've missed something and also to help
>
> > > > others understand the undertaking required for the infrastructure to
>
> > > > actually attempt it.
>
> > > >
>
> > > > #1 Local regulations and permits.
>
> > > >
>
> > > > First you have to check your launch site county laws and regulations
>
> > > > for a launch site.
>
> > > > It is a bit more complicated than that to select a launch depending on
>
> > > > what way your are approaching the FAA for a launch permit. If you are
>
> > > > going for an "Experimental Launch Permit" and I will include that in
>
> > the
>
> > > > FAA section.
>
> > > >
>
> > > > Local Fire Marshal and compliance with NFPA Code 1127 this is a
>
> > > > national code but it get's resolved on the local level.
>
> > > >
>
> > > > You also have to resolve any other issues in the county of choice and
>
> > > > come into compliance.
>
> > > >
>
> > > > #2 State laws regulations and permits.
>
> > > >
>
> > > > The DOT has to be dealt with to insure compliance with state
>
> > > > regulations of transport of hazardous materials such as rocket
>
> > > > propellant and explosives and obtain the proper permits permits.
>
> > > >
>
> > > > I'm familiar with Texas regulations so I wont go into that because
>
> > it's
>
> > > > going to be different for every state but every state has regulations
>
> > > > and you must comply with your states regulations.
>
> > > >
>
> > > > #3 Federal Regulations
>
> > > >
>
> > > > FCC you need permits to operate your transmitters and so you must
>
> > > > comply.
>
> > > >
>
> > > > BATF Explosive permits and manufacturing permits.
>
> > > >
>
> > > > DOD I know my planned launch site has interference with military
>
> > > > operations is the same airspace and therefor I'll have to deal with the
>
> > > > DOD on that level your launch site may not.
>
> > > >
>
> > > > FAA top of my list is the 50 million bond insurance (last time I
>
> > > > checked). There are plenty of requirements for an experimental launch
>
> > > > permit and the only other one that is expensive or difficult is the
>
> > > > environmental impact survey. Which could cost a million or more. My
>
> > > > chosen site was once a bombing practice zone so the government does a
>
> > > > yearly survey that is public so that solves that issue for me.
>
> > > >
>
> > > > There is plenty more to the FAA permit but you can read that yourself.
>
> > > >
>
> > > > There is an export tax whenever anything leaves the country (including
>
> > > > satellites) and this requires a licensed export broker.
>
> > > >
>
> > > > #4 United Nations
>
> > > > You have to file with the united nations for a satellite permit.
>
> > > >
>
> > > > So in a nutshell.
>
> > > >
>
> > > > I can expand on any portion of this if anyone's interested. If you
>
> > > > think I left something out let me know I just flung this out off the
>
> > top
>
> > > > of my head but I think I covered all the basses?
>
> > > >
>
> > > > Monroe
>
> >
>
> >
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